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Old 13th Apr 2013, 22:11
  #13 (permalink)  
Sunfish
 
Join Date: Aug 2004
Location: moon
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The main problem is going to be selection and maintenance of the aim.

Unless you guys can get very very clear about what you want to do and encapsulate it in a single easily understood sentence you will fail.

I suggest that your objective is:

- Easily understood simple plain english regulations, universally applied the same way throughout the country. In other words standard weberian bureaucracy with no possibility of creative interpretation by either operator or CASA operatives. And enforced in a reasonable and fair manner in line with the concepts of equity, procedural fairness and natural justice


How you achieve that is another matter. I am a great believer in the "strategy follows structure" school of business planning.

If the regulations were written by one group and enforced by a separate entity and audited by an independent ATSB there would be hope that something like the above might be achievable. However with the current mishmash of CASA and ATSB, reform is impossible.

For example, it is risible to watch CASA attempting to lock the door after the horse has bolted by its sudden discovery of the issue of "Fatigue Management" having hung out Dominic James to dry over the Norfolk Island ditching, whitewashing his employers fatigue management process and now coming up with new standards that they previously said were not needed - and incorporated in their best crappy mind numbing legalese to boot:

Civil Aviation Order 48.1 Instrument 2013

.......And of course the double jeopardy problem remains. CASA must always have someone to prosecute and no liability itself:

16.1 It is a condition on each flight crew licence that the licence holder must not operate an aircraft if, considering the circumstances of the flight to be undertaken, he or she has reason to believe that he or she is suffering from, or is likely to suffer from, fatigue which may so impair performance that the safety of the operation may be affected.


16.2 An FCM employed by an AOC holder must, before any FDP, disclose to the AOC holder anything affecting the FCM or connected with the FDP, which he or she has reason to believe may affect his or her ability to meet the AOC holder’s fatigue risk management policies or the limits and requirements of the Appendix or Appendices that the holder has chosen to apply to the FCM.

Anyway, good luck, my guess is that this effort will once again fail. Don't be bought off with the standard bureaucratic tricks either (eg: A "working group" etc.)

Last edited by Sunfish; 13th Apr 2013 at 22:22.
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